Before the Excavator Arrives, Someone Needs to Ask the Asbestos Question
At a Glance
- Asbestos planning should happen before renovation or demolition begins.
- A proper survey helps prevent costly delays, change orders, and compliance problems.
- Owners, contractors, and subcontractors may all have responsibilities depending on the work.
- The goal is simple: know what is in the building and have a plan before demolition starts.
Demolition projects tend to create a sense of momentum.
The building is coming down. The schedule is set. Equipment is mobilizing. Contractors are lined up. Everyone is focused on getting started.
But on older buildings, there is one question that needs to be answered before the excavator ever touches the structure:
What are we dealing with from an asbestos standpoint?
That question sounds simple. In practice, it can affect the schedule, the budget, worker safety, regulatory compliance, waste handling, and even who is legally responsible when something goes wrong.
For property owners, developers, general contractors, municipalities, and restoration firms, asbestos should not be treated as an issue that belongs exclusively to the abatement contractor.
It is a project-planning issue.
Asbestos Has Not Gone Away
There is sometimes a perception that asbestos is primarily a problem associated with buildings from decades ago and that the industry has largely moved beyond it.
The reality is different.
Older commercial buildings, industrial facilities, schools, apartment buildings, municipal structures, and other properties may still contain asbestos-containing materials in many forms.
These can include materials associated with mechanical systems, flooring, roofing, insulation, surfacing materials, pipe insulation, and other building components.
The presence of asbestos does not automatically mean a building is dangerous.
In many situations, asbestos-containing materials that are intact and left undisturbed may be managed safely.
The risk changes when renovation or demolition begins.
Once materials are cut, broken, removed, pulverized, sanded, scraped, or otherwise disturbed, the project can move from ordinary construction activity into a highly regulated environmental and occupational-safety situation.
That is why asbestos planning needs to happen before demolition begins—not after suspect material is uncovered in the middle of the job.
The Owner and Contractor Both Need to Pay Attention
One of the most important points people miss about asbestos regulations is that responsibility does not necessarily stop with the company physically removing the material.
Under the federal Asbestos NESHAP program, building owners and contractors can both have responsibilities related to renovation and demolition activities.
Michigan’s asbestos regulatory structure also involves multiple agencies and requirements dealing with worker protection, contractor licensing, training, notification, emissions control, and waste handling.
That means the conversation should begin early.
Who has investigated the building?
What materials were identified?
Was the entire affected area evaluated?
What materials will be disturbed?
Does the planned work trigger notification requirements?
Who is responsible for submitting those notifications?
Will regulated asbestos-containing material need to be removed before demolition?
Who is coordinating the asbestos work with the demolition contractor?
Where is the waste going?
Those questions should be answered before the project reaches the field.
Trying to figure them out while demolition equipment is already sitting on site is rarely efficient.
An Asbestos Survey Is More Than a Box to Check
Environmental investigations are sometimes treated as administrative requirements.
Get the report.
Put it in the project folder.
Move on.
That misses the real value of the investigation.
A good asbestos survey is a planning tool.
It can help the project team determine what materials are present, where they are located, and how they may affect the proposed work.
That information influences decisions about sequencing, abatement, demolition methods, worker protection, waste disposal, scheduling, and cost.
The purpose is not simply to generate another document.
The purpose is to prevent surprises.
And in construction, surprises are expensive.
The Most Expensive Discovery Is the One Made During Demolition
Consider what happens when suspect material is discovered after demolition has already started.
Work may need to stop.
Additional sampling may be required.
Laboratory analysis may need to be performed.
An asbestos contractor may need to be mobilized.
Notifications may need to be evaluated.
The project schedule may change.
Waste that has already been generated may have to be handled differently.
Workers may need to be evaluated for potential exposure.
Questions may arise about who knew what—and when.
Now compare that with identifying the same material during pre-demolition planning.
The material still has to be dealt with.
But now it can be incorporated into the scope, schedule, budget, and contractor coordination process.
That is the difference between managing an environmental condition and reacting to an environmental problem.
Demolition and Renovation Are Not the Same Thing as Abatement
Another common misunderstanding is assuming that asbestos regulations only matter when someone intentionally hires an asbestos contractor.
That is not how the risk works.
A demolition contractor can disturb asbestos.
A plumber can disturb asbestos.
An HVAC contractor can disturb asbestos.
A roofer can disturb asbestos.
A flooring contractor can disturb asbestos.
A maintenance employee can disturb asbestos.
The material does not care what your scope of work says.
If the work impacts asbestos-containing material, applicable asbestos requirements can become relevant.
This is why communication between property owners, general contractors, environmental consultants, trades, and abatement contractors is critical.
Everyone who needs the information should have it before work begins.
OSHA Adds Another Layer
Environmental compliance is only part of the equation.
Worker protection requirements also matter.
MIOSHA’s asbestos construction standard addresses issues such as exposure assessments, regulated areas, respiratory protection, protective clothing, hygiene practices, communication of hazards, housekeeping, medical surveillance, competent-person responsibilities, and specific work practices for different classes of asbestos work.
This creates an important distinction.
A project can involve both:
Environmental requirements intended to prevent asbestos emissions into the surrounding environment, and
Occupational requirements intended to protect workers performing or working around the activity.
Project teams should understand both.
Meeting one set of requirements does not automatically mean the other has been addressed.
Good Projects Start With Better Questions
The strongest environmental programs I see are rarely the ones with the thickest compliance manuals.
They are the ones where people ask good questions early.
Before demolition or renovation begins, someone should be asking:
- What is the age and history of the building?
- What suspect materials are present?
- Has an appropriate asbestos inspection been completed?
- Does the inspection actually cover the areas affected by the planned work?
- Are additional destructive investigations needed?
- What asbestos-containing materials will be disturbed?
- What needs to be removed before the project begins?
- Who is responsible for regulatory notifications?
- What worker-protection requirements apply?
- How will asbestos waste be packaged, transported, documented, and disposed of?
- Have the general contractor and affected subcontractors been informed?
Those conversations can prevent a significant amount of confusion later.
Compliance Should Be Part of Preconstruction
Environmental compliance works best when it is integrated into the project—not added after the project has already been designed and scheduled.
The same way a project team evaluates structural conditions, utilities, access, logistics, and scheduling, environmental hazards should be part of preconstruction planning.
Asbestos is one example.
Lead, hazardous materials, contaminated soil, vapor intrusion, mold, and other environmental conditions can create similar challenges when they are discovered too late.
The principle is the same:
Identify the risk while you still have options.
Once demolition begins, your options usually become more expensive.
Ask the Question Before the Machine Starts
When an older building is scheduled for renovation or demolition, the asbestos conversation should not begin when someone sees suspicious insulation hanging from a broken pipe.
It should happen during planning.
Before mobilization.
Before demolition.
Before the schedule depends on everything going perfectly.
The question is simple:
Do we know what is in this building, and do we have a plan for dealing with it?
If the answer is uncertain, that is the time to find out.
Not after the excavator arrives.
What environmental challenges are you navigating in your facilities? I'd welcome the conversation — drop a comment or reach out directly.
Jeremy Westcott
Jeremy Westcott is Managing Director at Environmental Testing & Consulting, Inc., and a trusted advisor to contractors and facility managers on environmental compliance and enforcement.